Transformation Design and Operation Working Group Meeting 10 6 April 2020
Ground rules and virtual meeting protocols • Please place your microphone on mute, unless you are asking a question or making a comment. • Please keep questions relevant to the agenda item being discussed. • If there is not a break in discussion and you would like to say something, you can ‘raise your hand’ by typing ‘question’ or ‘comment’ in the meeting chat. Questions and comments can also be emailed to TDOWG@energy.wa.gov.au • The meeting will be recorded for minute-taking purposes. Please do not make your own recording of the meeting. • Please state your name and organisation when you ask a question to assist with meeting minutes. • If there are multiple people dialling in through a single profile, please email TDOWG@energy.wa.gov.au with the names of the attendees to be recorded in the minutes • If you are having connection/bandwidth issues, you may want to disable the incoming and/or outgoing video. Transformation Design and Operation Working Group meeting 10 2
Agenda • Generator Performance Standards: Regulatory framework, monitoring and rectification • Commissioning plan and process • Rule drafting plan Transformation Design and Operation Working Group meeting 10 3
Generator Performance Standards: Regulatory framework, monitoring and rectification Transformation Design and Operation Working Group meeting 10 4
Scope Previous Taskforce decisions Move Revised Generator Performance Create Register of Individual Generator Standards to the WEM Rules Performance Standards Monitoring Program Improve Compliance Framework - Self-monitoring - Early rectification - Central monitoring - Civil penalty framework Transformation Design and Operation Working Group meeting 10 5
Scope • Framework applies only to market participants with transmission connected generating facilities ‒ Includes those intending to register for market participation • Revised standards apply only to new generator connections, or existing generators seeking to undertake modifications ‒ No retrospective application of standards. Past exemptions from the Technical Rules will be retained • Flexibility for existing generators in developing monitoring programs ‒ Accounting for age, technology type and existing monitoring equipment ‒ Focus on reducing unnecessary costs • Process to be developed to backfill the register for existing generators ‒ Greater relevance for older generators (pre-1997 and to a lesser extent, 1997 - 2007) ‒ Process likely to require updated computer models Transformation Design and Operation Working Group meeting 10 6
Related work This is one of several projects relating to generator performance standards. Other key projects, and their relationship to this work, are: 1 2 3 4 WEM Monitoring Generator Generator Technical Rules and Compliance Compliance Performance Review Framework Implementing some Guideline In progress. Project running in decisions under this Completed in late Outcomes tandem using project 2018. complimentary common principles Implementing revised standards Transformation Design and Operation Working Group meeting 10 7
Overview of regulatory framework Minor changes to the Access Code are also required to limit the scope of the Technical Rules Framework commences February 2021 Transformation Design and Operation Working Group meeting 10 8
Connection and negotiation • Standards under the Generator Performance Guideline to be applied • Negotiated standards must be as close to possible to the ideal standard, having regard to: ‒ the need to protect the generator from damage; ‒ power system conditions at the location of the proposed connection; and ‒ the commercial and technical feasibility of complying with the ideal standard. • Trigger events permitted allowing a negotiated level of performance until trigger is reached Transformation Design and Operation Working Group meeting 10 9
Connection and negotiation • Western Power and AEMO will have a shared role in the negotiation of standards • Negotiation through Western Power ‒ Ensures all parties have access to the same information and generators are not required to engage with multiple parties on the same matters ‒ Nothing prevents generator from discussing directly with AEMO or jointly with AEMO and Western Power • Can accept, reject, or request further information. If rejecting, must provide an alternative standard that they would accept • WEM Rules dispute process will not apply to elements of chapter 3A • As per current process, certain generator modifications will require a new connection agreement and hence connection process Transformation Design and Operation Working Group meeting 10 10
Register • Register created and maintained by Western Power, with visibility provided to the ERA, AEMO and individual generators seeking access to their own data • Register to include: ‒ Status of connection ‒ Performance standards related to the new Appendix 12, including any negotiated performance standards and trigger events ‒ Generator’s computer model ‒ AEMO approved compliance self-monitoring plan • Register initially populated following network access contract agreement and updated as needed. Generators will have an obligation to advise Western Power when their situation changes, requiring that the register is updated Transformation Design and Operation Working Group meeting 10 11
Testing and approval to operate • New Market Procedure specifying testing requirements • Generator requirement to undertake appropriate tests prior to being granted interim approval to operate • Western Power will not be permitted to provide final approval to operate until: ‒ A monitoring plan has been approved by AEMO and has been added to the register ‒ The operational performance of the generator is considered satisfactory by both Western Power and AEMO ‒ The generator has demonstrated compliance to Western Power and AEMO’s satisfaction with the applicable generator performance standards • If, during testing, a generator’s performance is not as expected, the generator will be expected to bring the facility up to compliance. However where this can be demonstrated as unachievable, re-negotiation may be permitted if deemed appropriate by all parties Transformation Design and Operation Working Group meeting 10 12
Monitoring program Self-monitoring • Primary mechanism for ensuring compliance is through a self-monitoring plan ‒ Supported by central, non-invasive monitoring by AEMO and Western Power • Self-monitoring Market Procedure to be developed by AEMO ‒ Process for approval and amendment of plans ‒ Includes template self-monitoring plan • Connecting generators to develop a self-monitoring plan consistent with the template, for AEMO approval • Changes to the template can be applied retrospectively ‒ Generators will have 6 months to undertake the required changes and re- submit for AEMO approval • Generators may also request changes to their plans • Generators are not required to provide outcomes of their plans as a matter of course, but must do if requested by the ERA, AEMO or Western Power Transformation Design and Operation Working Group meeting 10 13
Addressing early non-compliance • Generators must report all instances of non-compliance with their generator performance standards to AEMO, whether discovered through their self- monitoring plan, or by any other means • Generators must also report if they cannot comply with the terms of their monitoring plan • In reporting non-compliance, generators may request a rectification plan. If agreed by AEMO, the generator must submit the plan with in 10 business days, unless agreed otherwise • Minimum information in the plan includes: ‒ the actions to be taken to rectify non-compliance ‒ the timeframes for the generator to become compliant ‒ any testing required to establish compliance with applicable generator performance standards • Alignment with wider WEM compliance framework, once implemented Transformation Design and Operation Working Group meeting 10 14
Addressing early non-compliance • AEMO to consider a rectification plan, consulting with Western Power ‒ Timeframe ‘best endeavours’ 10 business days ‒ Cannot approve if Western Power rejects • Once developed, a generator may request an amendment to plan for the approval of AEMO • Amnesty period applies from the time a generator’s request to develop a rectification plan is agreed, until either: ‒ A rectification plan is not submitted within the required timeframes; or ‒ A rectification plan is submitted, but not agreed; or ‒ A rectification plan is agreed, but is not complied with, and hence is cancelled by AEMO; or ‒ The rectification plan is agreed, but testing shows the generator remains non-compliant and an amendment to the plan could not be negotiated; or ‒ The rectification plan is successfully completed • Nothing will prevent a generator from undertaking action to remedy non- compliance, whether or not a rectification plan is agreed Transformation Design and Operation Working Group meeting 10 15
Addressing early non-compliance Transformation Design and Operation Working Group meeting 10 16
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